The Final Rule sets a cap of 21 cents on transactions that fall within its scope (plus 5 basis points on the transaction value) and requires issuers to place two unaffiliated marks, on every debit card. But the final rule does not answer every question about the original draft, and it does not account for many of the concerns raised in the public comments. Legal experts Tom Brown, Katherine Robison and Samuel Zun of O’Melveny & Myers LLP discuss the highlights. Read More